Sustainability claims for international markets

24th February 2025

Department of Agriculture Forestry and Fisheries
GPO Box 858
Canberra City ACT 2601

Email: credentials.innovation@aff.gov.au

Dear Sir/Madam

RE: Assuring agricultural sustainability claims: discussion paper

is pleased to comment on the Assuring Sustainability Claims
Discussion Paper (Discussion Paper) and supports the government in enhancing its understanding of proof for sustainability claims in international markets.

has represented the Australian value chain since
This industry-led organization encompasses the interests of all participants in the supply chain, including service providers, researchers, growers, traders and marketers (both domestic and export), processors (such as crushers, refiners, and manufacturers), and consumers.

establishes the framework for Australia's industry by setting standards for the production and trading of raw materials, as well as production standards for feed, food, and industrial applications.

The landscape of sustainability is both diverse and complex, highlighting the importance of ensuring that the approach taken to reach the goals set out is not simplistically implemented in a “one size fits all” manner. We welcome the opportunity to participate and facilitate a way forward that best addresses the needs of our customers, whilst minimising the impact on producers through regulatory burden.
works closely with to provide guidance to the grains industry and as such this response should be read in conjunction with their submission.

Current status and emerging opportunities.
Australian have been at the forefront of sustainability requirements for some time, responding effectively to the needs of our customers. In line with EU regulations under the Renewable Energy
Directive (RED III), the Australian canola industry has been successfully exporting sustainably certified canola to the EU since 2010. This is done under the International Sustainability and Carbon Certification
(ISCC) scheme – ISCC EU. This necessitates that the Australian industry’s greenhouse gas (GHG) footprint meets recognized target levels, along with ensuring that exports fulfill broader sustainability criteria.

established a central office to facilitate certification to the EU and this now operates as
. In addition to canola to the EU under ISCC-EU certification, also provides certification for the food and beverage sector under ISCC . And recently, achieved accreditation under ISCC which will enable certification of feedstocks for the emerging Sustainable Aviation
Fuel market.

ABN:
Currently, the industry is working on securing compliance with the US Renewable Fuel Standard to gain access to this market. With new markets continually developing globally, Australia is continually looking to maintain compliance with these sectors to ensure positive outcomes for trade and market access.

In 2019, established a ‘Central Office” to simplify and standardize the process for growers and participating companies. Now known as , 20 participating companies, have exported over 30 million tonnes since its inception, with over 5000 participating farms annually, thus validating
Australia’s farmers' sustainability credentials. In addition, also facilitates canola exports under the ISCC scheme.

Certification and traceability requirements.
Certification is a core tool as a means of demonstrating reliable, repeatable compliance with market and regulatory requirements.. To that end there are a number of factors that demonstrate what makes a good system of compliance:

• Alignment with global standards and recognition by global markets and customers

• End-User acceptance – For end-users who want to support sustainability claims, having the necessary
certification serves as proof of their commitment to stated sustainability goals and objectives.

Rigorous, but achievable standards – A “one size fits all” approach to sustainability fails to account for
the geographical diversity of our planet. Sustainability standards should acknowledge differences in
environmental conditions, land management practices, economic development, and technical
capabilities. Without this recognition, there is a risk of unintended consequences that could negatively
impact production, supply chain costs, food security, and the environment.

uses its Central Office model to engage with global certification bodies to advocate for Australia’s
sustainable practices aligned with its environment to be considered in sustainability frameworks.
Of note, co-mingled supply chains, such as grain, present a unique set of challenges concerning
provenance, an often recognised standard in sustainability frameworks. Here, a “mass balance”
approach is the most logical and practical application to large-scale traceability and sustainability
compliance where required to deliver compliance and value.

• Ease of compliance – Ensuring that the regulatory burden for suppliers is not so significant that it
confuses, disincentivizes, or overly complicates the compliance process, to the extent that they seek
alternative market paths at their own opportunity cost.

• Adaptative, and responsive to stakeholders – Certification frameworks should be dynamic, adapting to
the ever-changing market conditions and the evolving needs of both supply and demand. It is essential
to balance the rigor of testing methods with the flexibility of metrics as markets progress.

• Independently audited – 3rd party audit is important to create trust and demonstrate proof of
compliance. An independent auditsed system builds stakeholder confidence.
The Australian canola industry, and the broader grain industry, has an established and efficient system to meet commercial and regulatory requirmements. This supports Australia’s reputation in global markets and trade based on its regulatory standards, systems, and processes.

However, sustainability and traceability requirements are increasing globally and have the potential to impose undue regulatory burdens on the sector. encourages the Government to address these actions where they create trade inhibiting Non-Tariff Measures (NTMs). While we recognise that objective/intent can be valid, the implementation if not practical and science/risk based,can create a considerable cost and administrative burden without achieving the outcome sought e.g. EU Union Biofuels Database.

While is supportive of the approach adopted by The Australian Agricultural Traceability Assuring
Sustainability Claims Working Group (ASCWG) in considering the three identified aspects, we would also encourage the Working Group to note the systems already in place for verification for market access purposes such as .

Page 2
ABN:
Future challenges.

Sustainability has emerged as a key global priority, with both public and private sectors sharing the responsibility to ensure that projects, commitments, and initiatives effectively contribute to achieving stated targets. The role of government is vital in ensuring that environmental and trade policies provide a trade facilitative framework. Organisations such as facilitate compliance with globally recognized certification schemes. This is suppoted by other industry good activities that validate and promote the
Australian grain industry’s sustainability credentials.

With the government leading the development of policy frameworks for environmental and trade issues, the stands by its more than years of leadership in providing ongoing direction for the industry as the sustainability imperative continues to evolve. We appreciate the opportunity provided by DAFF to offer feedback on the Discussion Paper and support the government’s objective of enhancing its research knowledge and understanding of international market requirements for substantiating sustainability claims.

I look forward to the progress of this work and further opportunities to engage and provide input.

Thank you for your consideration of this response.

Manager,

Page 3
ABN: